SEC Petition Evaluation Report
 

Petition SEC-00107
 

Report Rev #:_ 1__ Report Submittal Date: January 28, 2011 

Subject Expert(s): David Allen, Thomas Tomes 

Site Expert(s): Frank C. Crawford 

Petition Administrative Summary 

Petition Under Evaluation 

Petition # Petition 

Type 

Petition 

Qualification Date 

DOE/AWE Facility Name 

SEC-00107 83.13 July 1, 2008 Linde Ceramics Plant 

Petitioner Class Definition 

All employees who worked at the Linde Ceramics Plant in Tonawanda, New York, during the applicable covered residual 

radiation period from January 1, 1954 through July 31, 2006. 

Class Evaluated by NIOSH 

All Department of Energy and Atomic Weapons Employer employees who worked at the Linde Ceramics Plant in 

Tonawanda, New York, during the period from January 1, 1954 through July 31, 2006. 

NIOSH-Proposed Class(es) to be Added to the SEC 

None 

Related Petition Summary Information 

SEC Petition 

Tracking #(s) 

Petition Type DOE/AWE Facility Name Petition Status 

SEC-00106, 

SEC-00107, 

SEC-00112, and 

SEC-00127 

83.13 Linde Ceramics Plant 

SEC-00106—Closed 

SEC-00107 and SEC-00112 have been merged 

SEC-00127—Preparing qualification 

Related Evaluation Report Information 

Report Title DOE/AWE Facility Name 

NA NA 

DCAS Health Physicist: Frank C. Crawford
 

Peer Review Completed By: [Signature on file] 

LaVon B. Rutherford 

1/28/2011 

Date 

SEC Petition Evaluation Reviewed By: [Signature on file] 

J. W. Neton 

1/28/2011 

Date 

SEC Evaluation Approved By: [Signature on file] 

Stuart L. Hinnefeld 

1/28/2011 

Date 

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SEC-00107 01-28-11 Linde Ceramics Plant 

Evaluation Report Summary: SEC-00107, Linde Ceramics Plant 

This is a revised evaluation report by the National Institute for Occupational Safety and Health (NIOSH) 

addressing a class of employees proposed for addition to the Special Exposure Cohort (SEC) per the Energy 

Employees Occupational Illness Compensation Program Act of 2000, as amended, 42 U.S.C. § 7384 et seq. 

(EEOICPA) and 42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as Members of the Special 

Exposure Cohort under the Energy Employees Occupational Illness Compensation Program Act of 2000. The 

revised document has been updated by NIOSH to reflect additional information and conclusions that were 

reached during deliberations of the Linde Working Group. Most notably, NIOSH has incorporated a revised 

methodology for reconstructing dose during the building renovation period, and has also added a method for 

bounding radon exposures in the underground utility tunnels. 

Petitioner-Requested Class Definition 

Petition SEC-00107, qualified on July 1, 2008, requested that NIOSH consider the following class: All 

employees who worked at the Linde Ceramics Plant in Tonawanda, New York, during the applicable covered 

residual radiation period from January 1, 1954 through July 31, 2006. 

Class Evaluated by NIOSH 

Based on its preliminary research, NIOSH accepted the petitioner-requested class. NIOSH evaluated the 

following class: All Department of Energy and Atomic Weapons Employer employees who worked at the 

Linde Ceramics Plant in Tonawanda, New York, during the period from January 1, 1954 through July 31, 2006. 

NIOSH-Proposed Class to be Added to the SEC 

Based on its full research of the class under evaluation, NIOSH has obtained air monitoring data, soil sampling 

data, and radiation contamination survey data from the clean-up period occurring prior to 1954, and for the time 

period evaluated in this report. Based on its analysis of these available resources, NIOSH found no part of the 

class under evaluation for which it cannot estimate radiation doses with sufficient accuracy. 

Feasibility of Dose Reconstruction 

Per EEOICPA and 42 C.F.R. § 83.13(c)(1), NIOSH has established that it has access to sufficient information 

to: (1) estimate the maximum radiation dose, for every type of cancer for which radiation doses are 

reconstructed, that could have been incurred in plausible circumstances by any member of the class; or (2) 

estimate radiation doses of members of the class more precisely than an estimate of maximum dose. 

Information available from the site profile and additional resources is sufficient to document or estimate the 

maximum internal and external potential exposure to members of the proposed class under plausible 

circumstances during the specified period. 

Health Endangerment Determination 

Per EEOICPA and 42 C.F.R. § 83.13(c)(3), a health endangerment determination is not required because 

NIOSH has determined that it has sufficient information to estimate dose for the members of the proposed 

class. 

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SEC-00107	 01-28-11 Linde Ceramics Plant 

Table of Contents
 

Evaluation Report Summary: SEC-00107, Linde Ceramics Plant.......................................................... 3
 

1.0 Purpose and Scope.......................................................................................................................... 7
 

2.0 Introduction .................................................................................................................................... 7
 

3.0 SEC-00107, Linde Ceramics Plant Definitions.............................................................................. 8
 

3.1 Petitioner-Requested Class Definition and Basis .................................................................. 8
 

3.2 Class Evaluated by NIOSH ................................................................................................... 9
 

3.3 NIOSH-Proposed Class to be Added to the SEC .................................................................. 9
 

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class ............................................................. 9
 

4.1 Exposure Matrix Site Profile ............................................................................................... 10
 

4.2 Technical Information Bulletin (TIB) ................................................................................. 10
 

4.3 Facility Employees and Experts .......................................................................................... 10
 

4.4 Previous Dose Reconstructions ........................................................................................... 11
 

4.5 NIOSH Site Research Database .......................................................................................... 12
 

4.6 Other Technical Sources...................................................................................................... 12
 

4.7 Documentation and/or Affidavits Provided by Petitioners ................................................. 12
 

5.0 Radiological Operations Relevant to the Class Evaluated by NIOSH ......................................... 14
 

5.1 Linde Ceramics Plant and Process Descriptions ................................................................. 14
 

5.2 Radiological Exposure Sources at the Linde Ceramics Plant.............................................. 18
 

5.2.1 Internal Radiological Exposure Sources ................................................................. 18
 

5.2.2 External Radiological Exposure Sources ................................................................ 18
 

5.2.2.1	 Photon....................................................................................................... 18
 

5.2.2.2	 Beta........................................................................................................... 18
 

5.2.2.3	 Neutron ..................................................................................................... 19
 

6.0 Summary of Available Monitoring Data for the Class Evaluated by NIOSH ............................. 19
 

6.1 Available Internal Monitoring Data .................................................................................... 19
 

6.2 Available External Monitoring Data ................................................................................... 19
 

7.0 Feasibility of Dose Reconstruction for the Class Evaluated by NIOSH ...................................... 20
 

7.1 Pedigree of Linde Ceramics Plant Data............................................................................... 20
 

7.1.1 Internal Monitoring Data Pedigree Review............................................................. 20
 

7.1.2 External Monitoring Data Pedigree Review............................................................ 21
 

7.2 Evaluation of Bounding Internal Radiation Doses.............................................................. 21
 

7.2.1 Methods for Bounding Internal Doses .................................................................... 22
 

7.2.1.1	 Exposure During General Building Occupancy (no renovation or
 

remediation activities) .............................................................................. 22
 

7.2.1.2	 Exposure from Outdoor Soil Contamination............................................ 22
 

7.2.1.3	 Exposure During Building Renovation .................................................... 22
 

7.2.1.4	 Exposure During Site Remediation (FUSRAP) ....................................... 24
 

7.2.1.5	 Exposure in the Utility Tunnel Complex.................................................. 24
 

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7.2.2 Internal Dose Reconstruction Feasibility Conclusion ............................................. 25
 

7.3 Evaluation of Bounding External Radiation Doses............................................................. 25
 

7.3.1 Methods for Bounding External Doses ................................................................... 25
 

7.3.2 Linde Ceramics Plant Occupational X-Ray Examinations ..................................... 26
 

7.3.3 External Dose Reconstruction Feasibility Conclusion............................................ 26
 

7.4 Evaluation of Petition Basis for SEC-00107....................................................................... 26
 

7.4.1 Dosimetry Data Concerns........................................................................................ 26
 

7.4.2 Alpha-Emitting Dust ............................................................................................... 27
 

7.5 Summary of Feasibility Findings for Petition SEC-00107.................................................. 28
 

8.0 Evaluation of Health Endangerment for Petition SEC-00107...................................................... 28
 

9.0 NIOSH-Proposed Class for Petition SEC-00107 ......................................................................... 29
 

10.0 References .................................................................................................................................... 31
 

Attachment 1: Data Sources on Uranium Progeny Concentrations in Linde Materials........................ 39
 

Attachment 2: Bounding Internal Dose from Particulates in the Linde Utility Tunnels....................... 41
 

Attachment 3: Bounding Radon Dose in the Linde Utility Tunnels ..................................................... 43
 

Tables 

4-1: No. of Linde Ceramics Plant Claims Submitted Under the Dose Reconstruction Rule ............... 11
 

5-1: Activities and Operations at Linde Ceramics ................................................................................ 15
 

5-2: Types of Feed Material Used in the Operation of the Linde Ceramics Plant ................................ 16
 

5-3: Linde Ceramics Timeline for the Evaluated Period....................................................................... 17
 

7-1: Summary of Feasibility Findings for SEC-00107.......................................................................... 28
 

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SEC-00107 01-28-11 Linde Ceramics Plant 

SEC Petition Evaluation Report for SEC-00107
 

ATTRIBUTION AND ANNOTATION: The original (Rev. 0) version of this document has been revised
 

by Frank C. Crawford (NIOSH) to reflect additional information and conclusions reached during a
 

series of Linde Working Group meetings conducted since the original Evaluation Report was issued.
 

Conclusions in this Rev. 1 version were peer-reviewed by the individuals listed on the cover page.
 

The rationales for all conclusions in this document are explained in the associated text.
 

1.0 Purpose and Scope 

This report evaluates the feasibility of reconstructing doses for all Department of Energy and Atomic 

Weapons Employer employees who worked at the Linde Ceramics Plant in Tonawanda, New York, 

during the period from January 1, 1954 through July 31, 2006. It provides information and analyses 

germane to considering a petition for adding a class of employees to the congressionally-created SEC. 

This report does not make any determinations concerning the feasibility of dose reconstruction that 

necessarily apply to any individual energy employee who might require a dose reconstruction from 

NIOSH. This report also does not contain the final determination as to whether the proposed class 

will be added to the SEC (see Section 2.0). 

This evaluation was conducted in accordance with the requirements of EEOICPA, 42 C.F.R. pt. 83, 

and the guidance contained in the Office of Compensation Analysis and Support’s (OCAS) Internal 

Procedures for the Evaluation of Special Exposure Cohort Petitions, OCAS-PR-004. 

2.0 Introduction 

Both EEOICPA and 42 C.F.R. pt. 83 require NIOSH to evaluate qualified petitions requesting that the 

Department of Health and Human Services (HHS) add a class of employees to the SEC. The 

evaluation is intended to provide a fair, science-based determination of whether it is feasible to 

estimate with sufficient accuracy the radiation doses of the class of employees through NIOSH dose 

1 reconstructions.

42 C.F.R. § 83.13(c)(1) states: Radiation doses can be estimated with sufficient accuracy if NIOSH 

has established that it has access to sufficient information to estimate the maximum radiation dose, 

for every type of cancer for which radiation doses are reconstructed, that could have been incurred in 

plausible circumstances by any member of the class, or if NIOSH has established that it has access to 

sufficient information to estimate the radiation doses of members of the class more precisely than an 

estimate of the maximum radiation dose. 

Under 42 C.F.R. § 83.13(c)(3), if it is not feasible to estimate with sufficient accuracy radiation doses 

for members of the class, then NIOSH must determine that there is a reasonable likelihood that such 

radiation doses may have endangered the health of members of the class The regulation requires 

NIOSH to assume that any duration of unprotected exposure may have endangered the health of 

1 NIOSH dose reconstructions under EEOICPA are performed using the methods promulgated under 42 C.F.R. pt. 82 and 

the detailed implementation guidelines available at http://www.cdc.gov/niosh/ocas. 

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members of a class when it has been established that the class may have been exposed to radiation 

during a discrete incident likely to have involved levels of exposure similarly high to those occurring 

during nuclear criticality incidents. If the occurrence of such an exceptionally high-level exposure has 

not been established, then NIOSH is required to specify that health was endangered for those workers 

who were employed for at least 250 aggregated work days within the parameters established for the 

class or in combination with work days within the parameters established for other SEC classes 

(excluding aggregate work day requirements).

NIOSH is required to document its evaluation in a report, and to do so, relies upon both its own dose 

reconstruction expertise as well as technical support from its contractor, Oak Ridge Associated 

Universities (ORAU). Once completed, NIOSH provides the report to both the petitioner(s) and to the 

Advisory Board on Radiation and Worker Health (Board). The Board will consider the NIOSH 

evaluation report, together with the petition, petitioner(s) comments, and other information the Board 

considers appropriate, in order to make recommendations to the Secretary of HHS on whether or not 

to add one or more classes of employees to the SEC. Once NIOSH has received and considered the 

advice of the Board, the Director of NIOSH will propose a decision on behalf of HHS. The Secretary 

of HHS will make the final decision, taking into account the NIOSH evaluation, the advice of the 

Board, and the proposed decision issued by NIOSH. As part of this decision process, petitioners may 

seek a review of certain types of final decisions issued by the Secretary of HHS.

2

3.0 SEC-00107, Linde Ceramics Plant Definitions

The following subsections address the progression of the class definition for SEC-00107, Linde 

Ceramics Plant. When a petition is submitted by a claimant, the requested class definition is 

evaluated as submitted. If the available site information and data justify a change in the petitioner’s 

class definition, NIOSH will specify a modified class to be fully evaluated. After a complete analysis, 

NIOSH will determine whether to propose a class for addition to the SEC and will specify that 

proposed class definition.

3.1 Petitioner-Requested Class Definition and Basis

Petition SEC-00107, qualified on July 1, 2008, requested that NIOSH consider the following class for 

addition to the SEC: All employees who worked at the Linde Ceramics Plant in Tonawanda, New 

York, during the applicable covered residual radiation period from January 1, 1954 through July 31, 

2006. 

The petitioner provided information and affidavit statements in support of the petitioner’s belief that 

accurate dose reconstruction over time is impossible for the Linde Ceramics Plant workers in 

question. During the qualification of Petition SEC-00107, NIOSH deemed the following information 

and affidavit statements sufficient to qualify SEC-00107 for evaluation:

The petition, received on March 3, 2008, and the six supporting documents, including 11 

affidavits from 8 former workers, were intended to support the petition bases F.1, F2, F.3, and F.4. 

 2 See 42 C.F.R. pt. 83 for a full description of the procedures summarized here. Additional internal procedures are 

available at http://www.cdc.gov/niosh/ocas.
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

SEC-00107 01-28-11 Linde Ceramics Plant 

NIOSH’s review of the documentation found that insufficient support for the bases was provided 

in the petition package. However, based on a review of the available records for Linde Ceramics 

claimants who were employed during the period included in the proposed class definition, NIOSH 

found that personal monitoring data was unavailable. 

During the qualification of Petition SEC-00107, NIOSH captured some personnel monitoring data for 

workers at Linde Ceramics between 2000 and November 2003, part of the period under evaluation, 

and uploaded that data into the NIOSH Site Research Database (SRDB) (IT Corporation, 2000-2003). 

Based on its Linde Ceramics Plant research and data capture efforts, NIOSH determined that it has 

access to area monitoring and exposure scenario information for Linde Ceramics Plant workers during 

the time period under evaluation. However, NIOSH also determined that limited personnel 

monitoring records are available for the time period being evaluated. NIOSH concluded that there is 

sufficient documentation to support the petition basis that internal and external radiation exposures 

and radiation doses were not adequately monitored at Linde Ceramics, for at least part of the proposed 

time period. While it seemed likely that exposures during the residual period could be bounded using 

exposure data from the operational period in conjunction with the comparison of process knowledge 

and source term information from the operational and residual periods, that assumption required the 

validation of a rigorous evaluation. NIOSH qualified the petition for further consideration by NIOSH, 

the Board, and HHS. The details of the petition basis are addressed in Section 7.4. 

3.2 Class Evaluated by NIOSH 

Based on its preliminary research, NIOSH accepted the petitioner-proposed class because NIOSH was 

unable to locate personal monitoring data for members of the proposed class and has reason to 

believe, based on the nature of activities during the residual period, that workers were unmonitored 

during the period proposed for evaluation. Therefore, NIOSH defined the following class for further 

evaluation: All Department of Energy and Atomic Weapons Employer employees who worked at the 

Linde Ceramics Plant in Tonawanda, New York, during the period from January 1, 1954 through July 

31, 2006. 

3.3 NIOSH-Proposed Class to be Added to the SEC 

Based on its research, NIOSH has obtained air monitoring data, soil sampling data, and radiation 

contamination survey data specific to the Linde site, which can be used to bound exposures to all 

members of the proposed class. Based on its analysis of these available resources, NIOSH found no 

part of the class under evaluation for which it cannot estimate radiation doses with sufficient accuracy. 

4.0 Data Sources Reviewed by NIOSH to Evaluate the Class 

NIOSH identified and reviewed numerous data sources to determine information relevant to 

determining the feasibility of dose reconstruction for the class of employees under evaluation. This 

included determining the availability of information on personal monitoring, area monitoring, 

industrial processes, and radiation source materials. The following subsections summarize the data 

sources identified and reviewed by NIOSH. 

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4.1 Exposure Matrix Site Profile 

An Exposure Matrix Site Profile provides specific information concerning the documentation of 

historical practices at the specified site. Dose reconstructors can use the Site Profile to evaluate 

internal and external dosimetry data for monitored and unmonitored workers, and to supplement, or 

substitute for, individual monitoring data. As part of NIOSH’s evaluation detailed herein, it examined 

the following TBDs for insights into Linde Ceramics Plant operations or related topics/operations at 

other sites: 

•	 An Exposure Matrix for Linde Ceramics Plant (Including Tonawanda Laboratory), ORAUTTKBS-0025; Rev. 00 PC-1; January 19, 2006; SRDB Ref ID: 22268 (ORAUT-TKBS-0025) 

4.2 Technical Information Bulletin (TIB) 

A Technical Information Bulletin (TIB) is a general working document that provides guidance for 

preparing dose reconstructions at particular sites or categories of sites. NIOSH reviewed the 

following TIB as part of its evaluation: 

•	 TIB: Estimation of Ingestion Intakes, OCAS-TIB-009; April 13, 2004; SRDB Ref ID: 22397 

(OCAS-TIB-009) 

•	 TIB: Dose Reconstruction During Residual Radioactivity Periods at Atomic Weapons Employer 

Facilities, ORAUT-OTIB-0070, Rev. 00; March 10, 2008; SRDB Ref ID: 41603 (ORAUT-OTIB0070) 

4.3 Facility Employees and Experts 

To obtain additional information, NIOSH interviewed 8 former Linde Ceramics employees and 

reviewed a 1981 memorandum that included ORAU interview questions and responses from a former 

Linde Ceramics employee. 

•	 Personal Communication, 2008, Personal Communication with Inventory Clerk/Rigger; 

Telephone Interview by ORAU Team HP and NIOSH HP; September 3, 2008; SRDB Ref ID: 

48679 (Name Two, September 3, 2008) 

•	 Personal Communication, 2008, Personal Communication with Trades Helper/Pipefitter; 

Telephone Interview by ORAU Team HP; September 4, 2008; SRDB Ref ID: 48680 (Name 

Three, September 4, 2008) 

•	 Personal Communication, 2008, Personal Communication with Tool Maintenance/Inspector/Truck 

Lift Operator; Telephone Interview by ORAU Team HP; September 11, 2008; SRDB Ref ID: 

48675 (Name Four, September 11, 2008) 

•	 Personal Communication, 2008, Personal Communication with Chemical Operator/Storesman; 

Telephone Interview by ORAU Team HP; September 11, 2008; SRDB Ref ID: 48676 (Name 

Five, September 11, 2008) 

•	 Personal Communication, 2008, Personal Communication with Chemical Operator; Telephone 

Interview by ORAU Team HP; September 11, 2008; SRDB Ref ID: 48677 (Name Six, September 

11, 2008) 

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•	 Personal Communication, 2008, Personal Communication with Technologist; Telephone 

Interview by ORAU Team HP; September 12, 2008; SRDB Ref ID: 48678 (Name Seven, 

September 12, 2008) 

•	 Personal Communication, 1981; Interview with [Name Eight Redacted], A Former Linde 

Employee, Oak Ridge Associated Universities Memorandum with attachments; April 10, 1981; 

SRDB Ref ID: 3745 (Name Eight, April 10, 1981) 

•	 Personal Communication, 2004, Email Communication with [Name Nine Redacted], email with 

attachment; October 8, 2004; SRDB Ref ID: 14580 (Name Nine, October 8, 2004) 

•	 Personal Communication, 2008, Personal Communication with [Name Ten Redacted], Telephone 

Interview by ORAU Team HP; September 22, 2008; SRDB Ref ID: 49406 (Name Ten, September 

22, 2008) 

•	 Personal Communication, 2010, Personal Communication with Electrician, Telephone Interview 

by ORAU Team HP; March 4, 2010; SRDB Ref ID: 80052 (Name Eleven, March 4, 2010) 

•	 Personal Communication, 2010, Personal Communication with Maintenance Staff Member, 

Telephone Interview by ORAU Team HP; March 10, 2010; SRDB Ref ID: 80055 (Name Twelve, 

March 10, 2010) 

•	 Personal Communication, 2010, Personal Communication with Maintenance Staff Member, 

Telephone Interview by ORAU Team HP; March 11, 2010; SRDB Ref ID: 80056 (Name 

Thirteen, March 11, 2010) 

4.4 Previous Dose Reconstructions 

NIOSH reviewed its NIOSH OCAS Claims Tracking System (NOCTS) to locate EEOICPA-related 

dose reconstructions that might provide information relevant to the petition evaluation. Table 4-1 

summarizes the results of this review. (NOCTS data available as of January 26, 2011) 

Table 4-1: No. of Linde Ceramics Plant Claims Submitted Under the Dose Reconstruction Rule 

Description Totals 

Total number of claims submitted for dose reconstruction 247 

Total number of claims submitted for energy employees who meet the definition criteria for the class 

under evaluation (January 1, 1954 through July 31, 2006) 210 

Number of dose reconstructions completed for energy employees who meet the definition criteria for 

the class under evaluation. 166 

Number of claims for which internal dosimetry records were obtained for the identified years in the 

evaluated class definition 0 

Number of claims for which external dosimetry records were obtained for the identified years in the 

evaluated class definition 0 

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NIOSH reviewed each claim to determine whether internal and/or external personal monitoring 

records could be obtained for the employee. While there are several cases with dosimetry data, all 

data are from the operational period, prior to the residual radiation period under evaluation. 

4.5 NIOSH Site Research Database 

NIOSH also examined its Site Research Database (SRDB) to locate documents supporting the 

evaluation of the proposed class. Five hundred and sixty-four documents in this database were 

identified as pertaining to Linde Ceramics. These documents were evaluated for their relevance to 

this petition. The documents include historical background on process description, process materials, 

dust sampling, air monitoring, site cleanup, and Formerly Utilized Sites Remedial Action Program 

(FUSRAP) information. 

4.6 Other Technical Sources 

The Linde Remedial Action Project maintains a website containing a summary of the monthly air 

sample data (from July 2000 through December 2002) collected at eleven locations around the 

perimeter of the Linde Ceramics/Praxair facility in Tonawanda, New York. The summary includes 

alpha spectroscopy results from radium-226, thorium-230, and uranium-238 for each air sampler. The 

web address is: http://web.ead.anl.gov/corps/linde/mondata/index.cfm. 

4.7 Documentation and/or Affidavits Provided by Petitioners 

In qualifying and evaluating the petition, NIOSH reviewed the following documents submitted by the 

petitioner: 

•	 Affidavits from Former Linde Ceramics Employees; May 2008; OSA Ref ID: 106081 pp. 16-24; 

OSA Ref ID: 105687 pp. 70-85 (Affidavits, 2008) 

•	 Linde Ceramics Special Exposure Cohort Application: January 1, 1954 through July 31, 2006, 

Form B Non-standard; Name One; March 3, 2008; OSA Ref ID: 105432 (Name One, March 3, 

2008) 

•	 Linde: Burlap Bag Issue Technical Call Notes, teleconference with SC&A, NIOSH, ORAU, 

Advisory Board, Linde Worker, and petitioner; notes created by S. Cohen and Associates 

(SC&A); February 13, 2008; OSA Ref ID: 105687 p. 40 (SC&A, February 2008) 

•	 Experimentation on High-Grade Ores at the Linde Air Products Company, correspondence; 

Hadlock; February 26, 1944; OSA Ref ID: 105687 p. 43 (Hadlock, 1944) 

•	 Experimentation on High-Grade Ores at the Linde Air Products Company, correspondence 

regarding previous letter on same subject; E. L. Van Horn; March 6, 1944; OSA Ref ID: 105687 

p. 44 (Van Horn, 1944) 

•	 Handling Drums, correspondence; author not legible; March 11, 1949; OSA Ref ID: 105687 pp. 

45-46 (Unknown author, 1949) 

•	 Rehabilitation of Lake Ontario Ordnance Works; R, C. Heatherton; October 14, 1949; OSA Ref 

ID: 105687 pp. 47-49 (Heatherton, 1949) 

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SEC-00107	 01-28-11 Linde Ceramics Plant 

•	 Reducing Exposures, single-page write-up; W. B. Harris; February 26, 1951; OSA Ref ID: 105687 

p. 50 (Harris, 1951) 

•	 Monthly Status and Process Report for March 1949, W. E. Kelley; April 7, 1949; OSA Ref ID: 

105687 pp. 51-61 (Kelley, 1949) 

•	 Health Hazards in NYOO Facilities Producing and Processing Uranium, select pages only; 

Atomic Energy Commission (AEC); April 18, 1949; OSA Ref ID: 105687 pp. 62-65 (AEC, 1949) 

•	 Regarding Dust Hazards in the Ceramics Plant, correspondence; E. C. Kent; July 13, 1948; OSA 

Ref ID: 105687 p. 66 (Kent, 1948) 

•	 Decontamination of Buildings Used for Processing Alpha Emitters, select pages only; Paul B. 

Klevin, William B. Harris, and Hanson I. Blatz; April 29, 1954; OSA Ref ID: 105687 pp. 67-68 

(Klevin, 1954) 

•	 Linde Ceramics SEC Petitions Addendum SEC Tracking Numbers: SEC00106 and SEC00107— 

Additional Issues and Supplementary Evidence Supporting Linde Ceramics Petitions SEC00106 

and SEC00107; Name One; March 28, 2008; OSA Ref ID: 105723; OSA Ref ID: 105687 pp. 28­

33 (Name One, March 28, 2008a) 

•	 Linde Ceramics SEC Petition Application: November 1, 1947 through December 31, 1953, 

supporting document from the petitioner; Name One; March 28, 2008; OSA Ref ID: 105724; OSA 

Ref ID: 105687 pp. 3-27 (Name One, March 28, 2008b) 

•	 Additional Issues and Supplementary Evidence Supporting Linde Ceramics SEC Petitions 

SEC00106 November 1, 1947 through December 31, 1953 and SEC00107 January 1, 1954 

through July 31, 2006, supporting document from the petitioner; Name One; April 25, 2008; OSA 

Ref ID: 105849 (Name One, April 25, 2008) 

•	 Additional Issues and Supplementary Evidence Supporting Linde Ceramics SEC Petition 

SEC00107 January 1, 1954 through July 31, 2006, supporting document from the petitioner; 

Name One; May 20, 2008; OSA Ref ID: 106080 (Name One, May 20, 2008) 

•	 Correspondence Regarding the Addition of a Class of Employees to the Special Exposure Cohort, 

correspondence between OCAS and the Department of Health and Human Services (DHHS); 

OCAS and DHHS; January 12, 2006 and February 23, 2006; OSA Ref ID: 106081 pp. 2-5 

(OCAS/DHHS, 2006) 

•	 FUSRAP Considered Sites Database Report, printout; Department of Energy (DOE); April 30, 

2008; OSA Ref ID: 106081 pp. 6-9 (DOE, 2008) 

•	 Report on Residual Radioactive and Beryllium Contamination at Atomic Weapons Employer 

Facilities and Beryllium Vendor Facilities, select pages only; National Institute for Occupational 

Safety and Health (NIOSH); December 2006; OSA Ref ID: 106081 pp. 10-12 (NIOSH, 2006) 

•	 Manhattan: The Army and the Atomic Bomb, select pages only; Vincent C. Jones; 1985; OSA Ref 

ID: 106081 pp. 13-15 (Jones, 1985) 

•	 Linde: Radiation Exposure to Ore-Containing Burlap Bags—Revision 1, Working Draft; S. Cohen 

& Associates (SC&A); June 10, 2008; OSA Ref ID: 106340 (SC&A, June 2008) 

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SEC-00107	 01-28-11 Linde Ceramics Plant 

5.0	 Radiological Operations Relevant to the Class Evaluated by 

NIOSH 

The following subsections summarize radiological conditions at the Linde Ceramics Plant for the 

periods from 1942 through 1953 and from January 1, 1954 through July 31, 2006. The subsections 

describe the information available to NIOSH to characterize particular exposure routes and radioactive 

contamination materials. The plant process descriptions for the operational years are provided for 

historical perspective and to help frame the picture of how the radiological conditions during the 

residual period came to be. From available sources NIOSH has gathered these process and source 

descriptions pertaining to the DOE-related radiological operations at Linde Ceramics, information 

regarding the identity and quantities of each radionuclide of concern, and information describing 

activities during which radiation exposures may have occurred, including the physical environment in 

which they may have occurred. The information included within this evaluation report is intended 

only to be a summary of the available information. 

5.1	 Linde Ceramics Plant and Process Descriptions 

During the period from 1942 through 1948, Linde Air Products Corporation (the company that ran the 

Linde Ceramics Plant and the Linde Air Facility in Buffalo, New York) was contracted to perform 

uranium separation. Linde Air Products Corporation was selected because of the expertise it acquired 

from working in the ceramics business. Linde Ceramics Plant processed uranium to produce the 

black, yellow, green, and brown "salts" used for coloring ceramic glazes. 

The following five buildings were involved in the MED activities that took place at the Linde 

Ceramics Site: 

• Building 14 

• Building 30 

• Building 31 

• Building 37 

• Building 38 

Building 14 was built by Union Carbide in the mid-1930s. Buildings 30, 31, 37, and 38 were built by 

MED on land owned by Union Carbide. With the termination of the MED contract in 1954, 

ownership was transferred to Linde Air Products Corporation. Building information is provided in 

Table 5-1. 

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Table 5-1: Activities and Operations at Linde Ceramics 

Building Activities/Operations Description 

14 Built in the mid-1930s by Union Carbide; vacated in March 2004; demolition began April 30, 2004. 

Served as a location of laboratory studies. 

Served as a pilot plant for uranium separation in the early part of MED operations. 

Most recently (before demolition) used for offices, research laboratories, and fabrication facilities. 

30 Built by MED on Union Carbide-owned land; ownership transferred to Linde Air Products Corporation; 

demolished September 5-19, 1998. 

Served as the primary processing building for Step I (ores to U3O8) and Step II (U3O8 to UO2) uranium 

processing during MED operations. 

Also used as the location for some processing of metallic nickel with nitric acid to produce nickel salt. 

D&D reported complete as of March 29, 1950. 

31 Built by MED on Union Carbide-owned land; ownership transferred to Linde Air Products Corporation; 

decontaminated in 1997. 

Served as a location of Step III (fluorination of UO2 to UF4) uranium separation processing during MED 

operations. 

Currently used for maintenance activities and offices; houses the Army Corp of Engineers FUSRAP 

operations offices. 

37 Built by MED on Union Carbide-owned land; ownership transferred to Linde Air Products Corporation; 

demolished in 1981. 

Used for Step III (fluorination of UO2 to UF4). Although no details have been found, the 16’X36’ footprint 

of the building indicates a minor role in Step III processes. 

38 Built by MED on Union Carbide-owned land; ownership transferred to Linde Air Products Corporation; 

demolished in 1996. 

Served as a location for Step III (fluorination of UO2 to UF4) uranium separation processing during MED 

operations. 

D&D began in November 1952. 

Sources: Name Nine, October 8, 2004; U.S. Army Corps, 1998; Bechtel, 1993; ORAUT-TKBS-0025, Section 2.6 

Under the MED contract, seven different sources of uranium were processed at Linde Ceramics: four 

African ores (three low-grade pitchblendes and a torbernite) and three domestic ores (carnotites from 

Colorado). Some of the domestic ores were actually tailings from vanadium processing and were preprocessed, in order to concentrate the uranium, prior to shipment from the western states. The 

majority of the radium in these ores was removed during the pre-processing. The African ores were 

unprocessed and contained all members of the uranium decay series, including radium in secular 

equilibrium with the uranium. As a result of the radium content, the African ores produced 

substantially higher levels of radon gas than the domestic ores. 

In 1943, following laboratory and pilot-plant studies, uranium processing began at Linde Ceramics. 

The uranium ores and tailings were processed in three steps: Step I involved uranium oxide (U3O8) 

being separated from the feedstock by acid digestion, followed by precipitation and filtration. Step II 

involved converting uranium oxide to uranium dioxide. Residues from Step II were recycled to Step 

I. In the final step of processing at Linde, Step III, uranium dioxide was converted to uranium 

tetrafluoride (Bechtel, 1990). Table 5-2 shows the types of feed material that were used in the 

operation of the Linde Ceramics Plant. 

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Table 5-2: Types of Feed Material Used in the Operation of the Linde Ceramics Plant

Type of Material Code Time Period when Processed Assay of U3O8

a

Colorado concentrates L-19 June 1943 – November 1943 12% - 14%

African pitchblende L-30 November 1943 – September 1944 8.2%

African pitchblende L-50 October 1944 – November 1944 4% - 6%

Colorado concentrates L-19 November 1944 – January 1946 16% - 18%

African pitchblende R-10 February 1946 – June 1946 2% - 3%

Torbernite Q-20 ~8.2%

Residues and scrap NA June 1943 – June 1946 Varying

Notes: 

Source: Reformatted version of Attachment included in Personal Communication, April 10, 1981.

Colorado concentrates were processed during about 50% of the time of operation of the Ceramics Plant.

The maximum quantity of ore processed in any week was 1.5 million pounds of R-10 a

Assay of uranium = Assay of U3O8 X 0.842

Step III shutdown occurred on June 30, 1949, and Linde Ceramics Plant cleanup began sometime 

before Step III shutdown. Some Step II equipment located in Building 30 was removed in March and 

April of 1948 (Heatherton, 1948, p. 108). Dismantling of Step I and remaining Step II equipment in 

Building 30 had begun by May 1949 (ORAUT-TKBS-0025). Shortly after the shutdown of Step III 

production, a comprehensive clean-up effort was undertaken to reduce levels of radioactivity in 

Building 30 to enable its release to Linde for unrestricted use (Heatherton, 1950). After removal of 

the bulk of the process equipment, the entire building was vacuum-cleaned and flushed with water. 

Afterwards, a systematic radiation survey was conducted to identify areas of contamination. 

Decontamination was accomplished primarily by removing contaminated parts of the building (such 

as portions of the second-floor balcony on which process operators had been stationed) and by 

abrading surfaces (mostly by sandblasting, although oxygen acetylene torches were also used). After 

each area was decontaminated, it was again cleaned and flushed, and a final radiation survey was 

performed. These activities were concluded prior to the release of the Linde facilities to Linde Air for 

private use in 1954, the start of this evaluation period.

In 1976, in the earliest stages of the FUSRAP, the Oak Ridge National Laboratory (ORNL, 19783) 

surveyed the Linde Tonawanda site, which included both the Linde Ceramics MED process buildings 

and the Tonawanda Lab, from October 18, 1976 through November 5, 1976. The purpose of the 

survey was to determine if remediation would be required. Radiation and radioactive contamination 

measurements were taken inside Buildings 14, 30, 31, 37, and 38, on the property outside of the 

buildings, and at nearby offsite locations. 

According to the ORNL 1978 survey report, by the mid-1970s, Building 37 was no longer used and 

was seldom entered. Building 30 had been renovated and converted into a warehouse for shipping 

and receiving. Building 14 housed fabrication facilities, research laboratories, and offices. Buildings 

30 and 14 had occupancy of 20-30 employees during normal working hours. Building 31 housed 

fabrication facilities offices and storage areas with a normal working hour occupancy of 12-20 

 3 The survey was conducted by ORNL in 1976; however, the report was not written until 1978. The survey conducted in 

1976 is referenced as ORNL, 1978 (the date of the report).
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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employees. Building 38 became a warehouse that was occupied for short intervals during a normal 

work week. 

Linde was designated as a FUSRAP site in 1980. Building 37 was demolished in August 1981. The 

FUSRAP remediation period for Linde Ceramics was from 1988 through 1992 and again in 1996. In 

August 1996, as part of the remediation, Building 38 was demolished. Since 1976, the site has 

undergone various attempts at remediation and is still undergoing remediation by the Army Corps of 

Engineers. Building 30 was demolished as of September 19, 1998. In March 2004, Building 14 was 

vacated and demolition commenced in June 2004. Building 31 is the only remaining MED process 

building still onsite, and is no longer occupied by Linde employees. 

The Bechtel 1993 Remedial Investigation Report (Bechtel, 1993) shows that areas of residual 

radioactive contamination were also associated with areas in or near Buildings 57, 58, and 90. The 

highest indoor radiation levels were found in the principal production buildings, Building 30 and 

Building 38. 

Table 5-3 shows selected events at Linde Ceramics for the period evaluated in this report. 

Table 5-3: Linde Ceramics Timeline for the Evaluated Period 

Year Event(s) 

1954-AEC contractual work comes to an end with completion of clean-up activities. 

1962-1970-Major renovation of Building 30. 

Former workers indicate that this was a period of almost continuous disruption within the 

building activities that could have potentially released and resuspended formerly inaccessible 

contamination. 

1976-ORNL performed a survey (surveyed Buildings 14, 30, 31, 37, 38, as well as external 

soil) as part of the FUSRAP program. 

1980-Linde designated as a FUSRAP site. 

August 1981-Demolition of Building 37 is completed by Union Carbide Corporation. 

1988-1992-FUSRAP remediation period. 

1996-FUSRAP remediation period. 

Demolition of Building 38 was completed by the DOE in August 1996 (Name Nine, October 

8, 2004) 

September 19, 1998-Demolition of Building 30 complete (U.S. Army Corps, 1998). 

March 2004-Building 14 vacated for demolition. 

Building demolition began in June 2004. 

2008-Building 31 occupied by ACE and currently used for office space. 

1955 

1965 

1975 

1985 

1995 

2005 

Note: Dates are identified as specifically as possible based on current information. 

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5.2 Radiological Exposure Sources at the Linde Ceramics Plant 

The following subsections provide an overview of the internal and external exposure sources for the 

Linde Ceramics Plant class under evaluation. Historical surveys and remediation investigation results 

indicate that the Linde property had four sources of MED-related radioactive contamination: (1) 

radioactive contamination in surface and subsurface soils, (2) residual radioactivity, primarily in the 

uranium processing buildings (Buildings 14, 30, 31, 37 and 38), (3) processing effluents disposed of 

onsite in injection wells and open pits, and (4) radioactive contamination in sediments found in 

building sumps and the storm and sanitary sewer systems. Waste materials (raffinates) were 

transported offsite (to Lake Ontario Ordnance Works and/or Ashland) prior to the end of operations 

(Argonne, 1987; Thornton, 1976; Aerospace Corporation, 1981; Anderson, 1945; Robinson, 1945; 

Malone, 1956; Robinson, 1973). Therefore, workers outside the operational period would have had 

minimal exposure potential to these materials in their concentrated form. The primary contaminants 

in the soil and sediments were uranium and uranium progeny. 

5.2.1 Internal Radiological Exposure Sources 

Linde used two types of starting materials for Step I (ore to U3O8) processing, generally referred to in 

Linde-related literature as African ore and domestic ore. Most of the African ore was pitchblende; 

some was torbernite (Aerospace Corporation, 1981, p. 819). Neither the pitchblende nor the torbernite 

underwent chemical preprocessing before being shipped to Linde. Therefore, besides uranium, the 

ores also contained all members of the uranium decay series, including radium and its progeny 

(ORAUT-TKBS-0025). From an internal exposure perspective, these radionuclides could have been 

present as residual radioactivity on surfaces at the Linde Ceramics site and could have become 

airborne during post-operation activities and subsequently inhaled or ingested by workers at the site. 

5.2.2 External Radiological Exposure Sources 

Employees could have received external radiation exposures from uranium and uranium progeny. The 

uranium content of mined uranium ores varied based on the assay of the rock being mined. Much of 

the potential for external exposure to workers was due to uranium progeny. Measured floor and wall 

surface contamination levels in 1976 in Building 30 were similar to 1950 post-decontamination 

measurements. 

5.2.2.1 Photon 

Photon emissions from uranium ore and concentrates potentially present during the evaluation period 

would include emissions from uranium and uranium progeny (mainly radium-226 and radium 

progeny). 

5.2.2.2 Beta 

Beta exposure would have resulted from uranium and its progeny. The dominant beta radiation source 

was from the uranium. In the uranium decay scheme, there is a short-lived isotope, protactinium234m. This isotope decays by emitting an energetic 2.28 MeV beta particle. It is this beta particle 

that accounts for shallow-dose hazard associated with the uranium. 

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5.2.2.3 Neutron 

NIOSH has determined that there was no significant neutron exposure concern at Linde Ceramics for 

the timeframe being evaluated (ORAUT-TKBS-0025). Therefore, due to the absence of neutron 

generating source material at the site, further assessment of potential neutron exposures for the 

proposed worker class is not included in this evaluation report. 

6.0	 Summary of Available Monitoring Data for the Class Evaluated 

by NIOSH 

The following subsections provide an overview of the state of the available internal and external 

monitoring data for the Linde Ceramics Plant class under evaluation. 

6.1	 Available Internal Monitoring Data 

No personnel bioassay monitoring results have been identified for Linde Ceramics workers during the 

residual period; however, NIOSH does have access to survey data, including air monitoring data, for 

both the decontamination activities at Linde (conducted just prior to the start of the residual radiation 

period) and several distinct, major investigations during the residual radiation period. The residual 

period surveys include soil characterizations, building surveys, and air sampling results. 

NIOSH has access to source term information for onsite uranium and uranium progeny during the 

operational period. As discussed, NIOSH also has radiological survey data from surveys conducted 

during the decontamination of the Linde facilities, following the cessation of operations and removal 

of source term materials (Kirk, 1954; Weinstein, 1954; Belmore, 1952; Klevin, 1954). Additionally, 

NIOSH has access to dust samples (AEC, 1954a), contamination smear samples (AEC, 1954b), 

FUSRAP remedial investigations (ORNL, 1978; Bechtel, 1993), final status surveys (IT Corporation, 

February 2002a; IT Corporation, February 2002b; IT Corporation, February 2002c; IT Corporation, 

February 2002d; IT Corporation, February 2002e; Shaw, February 2005a; Shaw, February 2005b; 

Shaw, February 2005c; Shaw, March 2005; Shaw, January 2005a; IT Corporation, January 2002a; IT 

Corporation, January 2002b; IT Corporation, March 2002; IT Corporation, September 2002;), and 

post remedial action data (Belmore, 1952; Klevin, 1954; Heatherton, 1950; McKenzie, 2000) 

documenting site contamination during the period evaluated in this report. 

6.2	 Available External Monitoring Data 

Limited personnel external dosimetry data have been located for Linde Ceramics workers during the 

residual period. Area monitoring data and contamination surveys performed as part of the FUSRAP 

and remediation surveys are available and provide information regarding potential external exposures 

to workers who worked at the site during the period evaluated in this report (Bechtel, 1993). 

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7.0	 Feasibility of Dose Reconstruction for the Class Evaluated by 

NIOSH 

The feasibility determination for the class of employees under evaluation in this report is governed by 

both EEOICPA and 42 C.F.R. § 83.13(c)(1). Under that Act and rule, NIOSH must establish whether 

or not it has access to sufficient information either to estimate the maximum radiation dose for every 

type of cancer for which radiation doses are reconstructed that could have been incurred under 

plausible circumstances by any member of the class, or to estimate the radiation doses to members of 

the class more precisely than a maximum dose estimate. If NIOSH has access to sufficient 

information for either case, NIOSH would then determine that it would be feasible to conduct dose 

reconstructions. 

In determining feasibility, NIOSH begins by evaluating whether current or completed NIOSH dose 

reconstructions demonstrate the feasibility of estimating with sufficient accuracy the potential 

radiation exposures of the class. If the conclusion is one of infeasibility, NIOSH systematically 

evaluates the sufficiency of different types of monitoring data, process and source or source term data, 

which together or individually might ensure that NIOSH can estimate either the maximum doses that 

members of the class might have incurred, or more precise quantities that reflect the variability of 

exposures experienced by groups or individual members of the class. This approach is discussed in 

OCAS’s SEC Petition Evaluation Internal Procedures which are available at 

http://www.cdc.gov/niosh/ocas. The next four major subsections of this Evaluation Report examine: 

• The sufficiency and reliability of the available data. (Section 7.1) 

• The feasibility of reconstructing internal radiation doses. (Section 7.2) 

• The feasibility of reconstructing external radiation doses. (Section 7.3) 

• The bases for petition SEC-00107 as submitted by the petitioner. (Section 7.4) 

7.1	 Pedigree of Linde Ceramics Plant Data 

This subsection answers questions that need to be asked before performing a feasibility evaluation. 

Data Pedigree addresses the background, history, and origin of the data. It requires looking at site 

methodologies that may have changed over time; primary versus secondary data sources and whether 

they match; and whether data are internally consistent. All these issues form the bedrock of the 

researcher’s confidence and later conclusions about the data’s quality, credibility, reliability, 

representativeness, and sufficiency for determining the feasibility of dose reconstruction. The 

feasibility evaluation presupposes that data pedigree issues have been settled. 

7.1.1	 Internal Monitoring Data Pedigree Review 

NIOSH did not locate any bioassay monitoring data for the period under evaluation. Therefore, an 

internal monitoring data sufficiency and pedigree evaluation is not possible for the internal monitoring 

data type. 

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It should be noted that the air sampling and survey data associated with the decontamination and 

decommissioning activities of 1949-1954 are contained in original reports, and are therefore primary 

data sources, as are the air samples and survey results reported by ORNL. Therefore, no additional 

pedigree review was performed for those data. The FUSRAP air monitoring results have 

been reviewed as part of the comparison performed for the feasibility determination in this report. 

Soil sampling data was reported by ORNL and the FUSRAP program. Again, considering the 

information is contained in original reports, and that the FUSRAP program has a robust and rigorous 

Quality Assurance program in place for its laboratory analysis, further pedigree assessment of those 

data was not performed for this evaluation. 

7.1.2 External Monitoring Data Pedigree Review 

NIOSH located limited external personnel dosimetry data for the period under evaluation. NIOSH has 

radiation dosimetry reports from Landauer, pertaining to IT Corp. Praxair workers from 2000 through 

2003. Landauer is currently and at the time of these reports, accredited by the National Institute of 

Standards and Technology through the National Voluntary Laboratory Accreditation Program. 

However, NIOSH did not locate any other external personnel dosimetry data for the period under 

evaluation. Therefore, an external data sufficiency and pedigree evaluation was not performed for the 

external monitoring data type. 

7.2 Evaluation of Bounding Internal Radiation Doses 

The principal source of internal radiation doses for members of the class under evaluation was the 

potential inhalation or ingestion of residual contamination in the uranium processing buildings 

(Buildings 14, 30, 31, 37, and 38) (Bechtel, 1993). Workers could have been exposed by the 

resuspension of uranium and uranium progeny contamination within the buildings. Outside the 

buildings, the potential resuspension of contaminated soils on the Linde site could also have exposed 

workers to uranium and uranium progeny. 

In all cases, ingestion intake rates can be estimated using OCAS-TIB-009. This method supports the 

estimation of the ingestion rate, in terms of dpm for an 8-hour workday by multiplying the air 

concentrations (in activity per cubic meter) by a factor of 0.2. 

ORAUT-TKBS-0025 assessed fifty-five measurements of radon progeny concentration that were 

taken in 1976 and 1981 in the Tonawanda site buildings, which were used in MED/AEC work 

(ORNL, 1978, pp. 17 and 84; Bechtel, 1982, p. B-24). The 1981 survey results were more 

comprehensive and yielded significantly higher concentrations; thus, the 1976 results were not used to 

assess radon exposure during the residual period. As discussed in ORAUT-TKBS-0025, Building 31 

had the highest radon progeny concentration. Based on the assessment of the dose, as discussed in 

ORAUT-TKBS-0025, applying a maximum exposure scenario using worst case conditions, radon 

exposures in all cases during the period evaluated in this report period can be bounded using the 

method defined in ORAUT-TKBS-0025. 

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7.2.1 Methods for Bounding Internal Doses 

Since NIOSH did not locate urinalysis, chest counting, or other bioassay monitoring data for the 

period under evaluation, internal exposure must be determined based on radiological source term and 

area monitoring data. Potential internal exposures from uranium and progeny for the class under 

evaluation can be divided into the following exposure scenarios: 1) exposure during general building 

occupancy (no renovation or remediation activities), 2) exposure from outdoor soil contamination, 3) 

exposure during building renovation, and 4) exposure during site remediation (FUSRAP). Evaluation 

of exposures for scenario one (general building occupancy) is based on methodology contained in 

ORAUT-TKBS-0025. 

7.2.1.1 Exposure During General Building Occupancy (no renovation or remediation activities) 

As previously discussed in this report, the indoor radiological conditions (as reported in ORNL, 1978) 

were reviewed and determined to be comparable to 1950 post-decontamination conditions. ORAUTTKBS-0025 assesses the residual period internal dose from uranium and progeny (for workers other 

than renovation/remediation workers) based on Building 30, the primary uranium processing building 

and the building determined in 1976 to be the most contaminated on the site. Because this method 

applies a maximum exposure scenario for work other than renovation/remediation work during the 

residual period, this method can be applied as a bounding approach for reconstructing internal dose for 

the proposed worker class, which includes workers other than renovation/remediation workers, 

evaluated in this report. After the end of the renovation period in 1969, NIOSH will use a 

straight-line decline of airborne contamination from 1970 to reach the levels measured in 1978 during 

the first FUSRAP survey. 

7.2.1.2 Exposure from Outdoor Soil Contamination 

A 1992 analysis (Murray, 1992) of the large soil mound (approximately an acre in area with vertical 

peaks, above-grade, of about four feet) on the Linde site, created by surface soils removed during site 

remediation, indicates that soil did not significantly contribute to exposures of site workers either as a 

result of direct exposure or through internal intakes from dust resuspension. The average soil 

concentration was less than the DOE guidelines in DOE 5400.5 for uranium and radium residual 

radioactivity in soil; the soil pile was recommended for unrestricted use. 

7.2.1.3 Exposure During Building Renovation 

Former Linde Ceramics Plant workers noted that Building 30 renovation occurred from 1954 through 

1969, although specific work details, including documentation of the actual start and end dates of 

renovation, dust control measures, location of work, and occupancy of areas are not available. 

Activities that could have caused the resuspension of fixed contamination occurred as part of Building 

30 renovation. It is reasonable to assume that this renovation work could have resulted in elevated 

airborne radioactivity; however, specific assessment of the potential doses associated with this work 

was not included in ORAUT-TKBS-0025. For the purposes of this evaluation and assessing the 

ability to bound radiological exposures for members of the proposed worker class, the renovation 

work will be compared to the operational period D&D work, which is included and assessed in 

ORAUT-TKBS-0025. 

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For the purpose of this evaluation, NIOSH is using the decontamination and decommissioning air 

sampling data, a highly conservative approach, to over-estimate the elevated airborne radioactivity 

associated with renovation work in Building 30 from 1954 to 1969. Given the nature of the original 

decontamination and decommissioning (D&D) activities, and the data associated with the original 

D&D work that indicate a reduction in overall contamination levels, it is reasonable to assume that the 

renovation activities of the 1960s would have resulted in lower airborne contamination levels than that 

measured during the original D&D work. 

Heatherton (1950) describes various methods for decontaminating hard surfaces at the Linde Ceramics 

Plant in Building 30. Included in Table V of Heatherton is summary data, showing the minimum, 

maximum, and average air concentrations measured during the evaluation of different 

decontamination options. Air dust samples were collected while vacuum cleaning rafters covered 

with radioactive dust, while sandblasting, and while using an oxygen blow pipe (Heatherton, 1950). 

In addition, another decontamination option was the removal of contaminated concrete brick and 

cinder block with a pneumatic hammer. In order to estimate the radioactivity hazards in performing 

this work, dust samples were taken and analyzed for gross alpha activity. The alpha activity data 

present values in terms of exposure in multiples of the Maximum Allowable Concentration (MACs), 

where a MAC is 70 dpm/meter3 alpha. Dust samples were collected both in the general area of the 

operation and in the breathing zone (Heatherton, 1950). 

Heatherton (1950) documents the results of air dust samples collected during six different kinds of 

D&D operations conducted in Building 30. NIOSH reviewed the operations for which dust samples 

were collected, as well as the number of samples per operation. The decontamination operation that 

consisted of pneumatic hammering of surfaces in Building 30 after previous sandblasting, was 

selected as the most similar to renovation work between 1954 and 1969. This type of activity was 

selected because: (1) former workers have indicated that jack hammering occurred during the building 

renovation period; (2) jack hammering represents an activity with the potential to raise significant 

levels of dust; and (3) dust raised by jack hammering conducted during the later renovation work on 

previously-decontaminated surfaces would most accurately be represented by the available breathing 

zone air sample. Heatherton records that breathing zone radioactive dust levels were found to reach a 

maximum level of 2.3 MAC. For purposes of dose reconstruction, NIOSH will use this dust level for 

workers in the Ceramics Plant at all times from 1954 through 1969. This is considered to be a very 

conservative exposure estimate for the following reasons: 

•	 Breathing zone levels would likely only be achieved by workers doing actual heavy renovation 

activities, such as jackhammering. At all other times, exposures would be much less. 

Measurements made in 1949/50 showed that, only 30 minutes after jackhammering ceased, 

airborne contamination fell by a factor of 22. In addition, general area exposures would be much 

less, even during jackhammering. 

•	 This exposure scenario assumes that renovation work in the Ceramics Plant buildings was a 

24 hr/day activity for a continuous period of 15 years. It is unlikely that an actual industrial 

facility could undergo such continuous renovation. 

•	 Decontamination activities, by their very nature, concentrated on the most-contaminated surfaces 

in the buildings. Renovation work would only involve the most-contaminated areas by random 

chance and are, thus, likely to produce much less airborne contamination overall. 

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Klevin (1954) documents the results of a preliminary and post-decontamination survey of Building 

30. The survey results clearly show a significant reduction in contamination levels. 

Waste materials (raffinates) were transported off site (to LOOW and/or Ashland) prior to the end of 

operations (Argonne, 1987; Thornton, 1976; Aerospace Corporation, 1981; Anderson, 1945; 

Robinson, 1945; Malone, 1956; Robinson, 1973). Therefore, workers outside the operational period 

would have had minimal exposure potential to this material in its concentrated form. To determine 

the exposure potential from residual surface contamination on the site, a review of available isotopic 

data was conducted. Isotopic data from soils and sediments on site are summarized in Attachment 1 

of this evaluation report and can be used to determine exposure from uranium progeny. 

7.2.1.4 Exposure During Site Remediation (FUSRAP) 

In 1980, Linde Ceramics was designated as part of FUSRAP and work under this program was 

performed during 1988-1992, and then again in 1996. The 1982 Bechtel preliminary evaluation of the 

Linde site reviewed the radiological health effects to remediation workers and concluded that the 

radiation protections in place would keep the internal exposures to a small fraction of the allowable 

limits (Bechtel, 1982, p. 17). NIOSH has determined that it would therefore be bounding to assess 

internal dose for remediation workers using the same methodology applied to renovation workers as 

discussed in Section 7.2.1.3 of this report. 

7.2.1.5 Exposure in the Utility Tunnel Complex 

The Linde site had a system of utility tunnels, constructed at different times, to carry steam, 

electricity, water, telephone lines, and other utilities from one part of the plant to another (Linde 

Drawing, 1937; Linde Drawing, 1957; Linde Drawing, 1961; Shaw, January 2005b). Documentary 

evidence shows that the first tunnel section was built in 1937 and ran from the powerhouse (Building 

8) past the Tonawanda Laboratory (Building 14, also called the Proving Laboratory) to Building 10. 

This part of the tunnel complex was not found to be contaminated with radium because the pre-war 

uranium-refining operations in Building 14 used pre-processed ores from the Colorado Plateau 

vanadium deposits, which did not contain radium. Borehole data from the site cited in the 1978 and 

1982 FUSRAP surveys confirmed that no excess radium was found in the soils near this section of 

tunnel (ORNL, 1978; Bechtel, 1982). Another section of tunnel was constructed in 1957 near 

Buildings 57, 58, and 31 in the northeastern area of the Ceramics Plant, and an extensive addition to 

the tunnel system was done in 1961 when the 1937 and 1957 tunnels were linked by new tunnels that 

ran between Buildings 30 and 31 and then branched south to Building 8 and west past Buildings 70, 2, 

and 2A. The 1957 and 1961 tunnel sections ran through areas of soil that were contaminated by 

radium-bearing ore and were subject to radon infiltration from this source. 

Exposure to radioactive airborne particulate matter in the utility tunnels was estimated based on 

residual surface contamination found in the 2002 Army Corps of Engineers study (U.S. Army Corps, 

2002). Although the tunnel system was only significantly contaminated in certain sections, NIOSH 

assumed that the entire tunnel system was uniformly contaminated at the 95th percentile level of 

measured contamination to bound the exposure from this source. Attachment 2 is an assessment of 

internal exposure from this source. During the renovation period, building levels of airborne 

radioactive particulate matter are considerably higher than utility tunnel levels; after 1970, this 

situation gradually reverses. 

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The underground tunnels may contain radon due to the radium contamination present in the tunnels 

and the surrounding soils. An upper estimate of the radon concentration in the utility tunnels was 

calculated to be 99.3 pCi/L based on a modified source-term method that was originally proposed by 

Sanford, Cohen & Associates. See Attachment 3 for details of this approach. 

7.2.2 Internal Dose Reconstruction Feasibility Conclusion 

Based on available Linde D&D survey data and residual radiation surveys conducted in association 

with FUSRAP activities, NIOSH has the necessary data to support bounding internal exposures for 

uranium, uranium progeny, and radon during the residual period. Radioactive operations terminated 

at the end of the operational period and source-term materials were removed from the site. The 

application of this survey data will result in overestimates of exposure and doses during the general 

activities and will result in conservative estimates of exposure during the highest-risk activities at 

Linde Ceramics during the period evaluated in this report (January 1, 1954 through July 31, 2006). 

7.3 Evaluation of Bounding External Radiation Doses 

The principal source of external radiation doses for members of the proposed class, other than medical 

X-rays required as a condition of employment, was direct beta-gamma exposures from residual 

contamination that was generated by uranium processing (Buildings 14, 30, 31, 37, and 38). Cleanup 

of the Linde Ceramics Plant facilities began before June 30, 1949 when Step III production was 

shutdown. As detailed in Section 5.1 of this evaluation report, decontamination and FUSRAP 

remediation investigations determined that residual radiation was located in various buildings across 

the Linde Ceramics site. Contamination was identified as fixed or transferable contamination within 

facilities and locations. Buildings were decontaminated in the late 1940s and early 1950s, prior to 

release for non-MED work; however, contamination located in unoccupied areas, such as the rafters, 

was not originally removed. Over time and with more restrictive clean-up standards, additional 

decontamination and/or demolition was required to meet facility release and/or occupancy 

requirements. 

The following subsections address the ability to bound external doses, methods for bounding doses, 

and the feasibility of external dose reconstruction. 

7.3.1 Methods for Bounding External Doses 

No personnel dosimetry data, other than the 2000 to 2003 monitoring data referenced in Section 3.1 

exist for the post-operational period. The radiological requirements of the residual radiation period 

did not require monitoring and/or providing dosimeters to site workers. Likewise, area survey 

monitoring was not generally performed at Linde after the cessation of processing, other than the 

remedial investigation surveys described in Section 5 of this evaluation report. 

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As previously discussed in this report, the indoor radiological conditions (as reported in ORNL, 1978) 

were reviewed and determined to be comparable to 1950 post-decontamination conditions. ORAUTTKBS-0025 assesses the external dose from uranium and progeny, based on Building 30, the primary 

uranium processing building and the building determined in 1976 to be the most contaminated on the 

site. Because this method applies a maximum external exposure scenario for any work at the Linde 

Ceramics site during the period evaluated in this report, this method can be applied as a bounding 

approach for reconstructing external dose for the proposed worker class, evaluated in this report. 

7.3.2 Linde Ceramics Plant Occupational X-Ray Examinations 

Pre-employment, repeat, and termination chest X-rays were required for at least some Linde Ceramics 

Plant workers. On certain occasions, pelvis X-rays were also required during the operational period 

(ORAUT-TKBS-0025). However, occupational X-ray examinations did not apply to the residual 

period under evaluation, and therefore are not considered in this evaluation report. 

7.3.3 External Dose Reconstruction Feasibility Conclusion 

NIOSH has established that it can bound the external exposures to Linde Ceramics workers during the 

period evaluated in this report (from January 1, 1954 through July 31, 2006), based on the available 

remedial investigation (FUSRAP) radiological surveys of the Linde facility. Given the half-lives of 

the source materials, NIOSH believes that the data collected during the residual period are 

conservative and adequate to bound the external doses to workers from 1954 through 2006. 

7.4 Evaluation of Petition Basis for SEC-00107 

The following subsections evaluate the assertions made on behalf of petition SEC-00107 for the Linde 

Ceramics Plant. 

7.4.1 Dosimetry Data Concerns 

SEC-00107: It was asserted that the dosimetry data available to NIOSH for Linde residual radiation 

workers were deficient, unreliable, and incomplete. 

Response: Linde Ceramics workers employed during the period under evaluation were not radiation 

workers. A radiation worker was an employee who had received specific training and qualifications 

allowing the worker to have unescorted access into the controlled area and to perform work of a 

radiological nature. 

With the decision to formally return the site to the control of Linde Air Products, further regulatory 

requirements for personnel dosimetry monitoring were neither required nor believed necessary. In 

retrospect, with information regarding the contamination and possible exposure pathways at Linde 

Ceramics, NIOSH determined that an evaluation of the data available to support dose reconstruction 

was warranted, and NIOSH has pursued the evaluation of the proposed class. 

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7.4.2 Alpha-Emitting Dust 

SEC-00107: It was asserted that the residual radiation workers that conducted renovation work were 

exposed to dangerous levels of alpha-emitting dust that would have resulted from uranium processing 

during the Linde operational time period. 

Response: This evaluation has taken into careful consideration the degree of contamination workers 

could potentially have been exposed to as a result of work activities during renovation of Linde 

process buildings, as described in the petitioner’s affidavit and interview. Using available survey and 

air monitoring data, an overestimating approach is available to NIOSH to bound the potential 

exposures of workers during renovation activities, as described in Sections 7.2 and 7.3. 

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7.5 Summary of Feasibility Findings for Petition SEC-00107 

This report evaluates the feasibility for completing dose reconstructions for employees at the Linde 

Ceramics Plant from January 1954 through July 2006. NIOSH found that the available monitoring 

records, process descriptions, and source term data available are sufficient to complete dose 

reconstructions for the evaluated class of employees. 

Table 7-1 summarizes the results of the feasibility findings at Linde Ceramics for each exposure 

source during the time period January 1954 through July 2006. 

Table 7-1: Summary of Feasibility Findings for SEC-00107 

January 1954 through July 2006 

Source of Exposure Reconstruction Feasible Reconstruction Not Feasible 

Internal1 X 

- U (total) and associated 

progeny 

X 

- Radon X 

External X 

- Gamma X 

- Beta X 

1 Internal includes an evaluation of airborne dust. 

As of January 26, 2011, a total of 210 claims have been submitted to NIOSH for individuals who 

worked at Linde Ceramics and are covered by the class definition evaluated in this report. Dose 

reconstructions have been completed for 166 individuals (~79%). 

8.0 Evaluation of Health Endangerment for Petition SEC-00107 

The health endangerment determination for the class of employees covered by this evaluation report is 

governed by both EEOICPA and 42 C.F.R. § 83.13(c)(3). Under these requirements, if it is not 

feasible to estimate with sufficient accuracy radiation doses for members of the class, NIOSH must 

also determine that there is a reasonable likelihood that such radiation doses may have endangered the 

health of members of the class. Section 83.13 requires NIOSH to assume that any duration of 

unprotected exposure may have endangered the health of members of a class when it has been 

established that the class may have been exposed to radiation during a discrete incident likely to have 

involved levels of exposure similarly high to those occurring during nuclear criticality incidents. If 

the occurrence of such an exceptionally high-level exposure has not been established, then NIOSH is 

required to specify that health was endangered for those workers who were employed for a number of 

work days aggregating at least 250 work days within the parameters established for the class or in 

combination with work days within the parameters established for one or more other classes of 

employees in the SEC. 

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SEC-00107 01-28-11 Linde Ceramics Plant 

Based on available data, knowledge of residual contamination levels and activities, and surveys 

conducted both at the start of and during the period evaluated in this report, NIOSH’s evaluation 

determined that it is feasible to estimate radiation dose for members of the proposed class with 

sufficient accuracy based on the sum of information available from available resources. Modification 

of the class definition regarding health endangerment and minimum required employment periods, 

therefore, is not required. 

9.0 NIOSH-Proposed Class for Petition SEC-00107 

Based on the entirety of its research of the class under evaluation, NIOSH found no part of said class 

for which it cannot estimate radiation doses with sufficient accuracy. This class includes all 

employees who worked at the Linde Ceramics Plant in Tonawanda, New York, during the period from 

January 1, 1954 through July 31, 2006. 

NIOSH has carefully reviewed all material sent in by the petitioner, including the specific assertions 

stated in the petition, and has responded herein (see Section 7.4). NIOSH has also reviewed available 

technical resources and many other references, including the Site Research Database (SRDB), for 

information relevant to SEC-00107. In addition, NIOSH reviewed its NOCTS dose reconstruction 

database to identify EEOICPA-related dose reconstructions that might provide information relevant to 

the petition evaluation. 

These actions are based on existing, approved NIOSH processes used in dose reconstruction for 

claims under EEOICPA. NIOSH’s guiding principle in conducting these dose reconstructions is to 

ensure that the assumptions used are fair, consistent, and well-grounded in the best available science. 

Simultaneously, uncertainties in the science and data must be handled to the advantage, rather than to 

the detriment, of the petitioners. When adequate personal dose monitoring information is not 

available, or is very limited, NIOSH may use the highest reasonably possible radiation dose, based on 

reliable science, documented experience, and relevant data to determine the feasibility of 

reconstructing the dose of an SEC petition class. NIOSH contends that it has complied with these 

standards of performance in determining the feasibility or infeasibility of reconstructing dose for the 

class under evaluation. 

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SEC-00107 01-28-11 Linde Ceramics Plant 

10.0 References 

42 C.F.R. pt. 81, Guidelines for Determining the Probability of Causation Under the Energy 

Employees Occupational Illness Compensation Program Act of 2000; Final Rule, Federal 

Register/Vol. 67, No. 85/Thursday, p. 22,296; May 2, 2002; SRDB Ref ID: 19391 

42 C.F.R. pt. 82, Methods for Radiation Dose Reconstruction Under the Energy Employees 

Occupational Illness Compensation Program Act of 2000; Final Rule; May 2, 2002; SRDB Ref ID: 

42 C.F.R. pt. 83, Procedures for Designating Classes of Employees as Members of the Special 

Exposure Cohort Under the Energy Employees Occupational Illness Compensation Program Act of 

2000; Final Rule; May 28, 2004; SRDB Ref ID: 22001 

42 U.S.C. §§ 7384-7385 [EEOICPA], Energy Employees Occupational Illness Compensation 

Program Act of 2000, as amended 

Battelle-TIB-5000, Default Assumptions and Methods for Atomic Weapons Employer Dose 

Reconstructions, PNWD-3741, Rev. 00; Battelle; April 2, 2007; SRDB Ref ID: 32016 

AEC, 1949, Health Hazards in NYOO Facilities Producing and Processing Uranium, select pages 

only; Atomic Energy Commission (AEC); April 18, 1949; OSA Ref ID: 105687 pp. 62-65 

AEC, 1954a, Various Dust Samples; Atomic Energy Commission (AEC); various dates throughout 

1954; SRDB Ref ID: 9132 

AEC, 1954b, Various Equipment Smears; Atomic Energy Commission (AEC); various dates 

throughout 1954; SRDB Ref ID: 9137 

Aerospace Corporation, 1981, Evaluation of the 1943-to-1946 Liquid Effluent Discharge from the 

Linde Air Products Company; The Aerospace Corporation; December 1981; SRDB Ref ID: 16979 pp. 

805-875 and SRDB Ref ID: 16512 

Affidavits, 2008, Affidavits from Former Linde Ceramics Employees; May 2008; OSA Ref ID: 

106081 pp. 16-24; OSA Ref ID: 105687, pp. 70-85 

Anderson, 1945, Sludges Stored on Haist Property as of 1 May 1945, Memorandum for Captain 

Russell E. Harris; Roy V. Anderson; June 13, 1945; SRDB Ref ID: 15426, p. 3 

Argonne, 1987, Proposed Remedial Actions at Four FUSRAP Sites in New York, selected pages; 

Argonne National Laboratory; July 1987; SRDB Ref ID: 16847, pp. 24-29 

Bechtel, 1982, Preliminary Engineering Evaluation of Remedial Action Alternatives; Bechtel National 

Inc. (Bechtel); November 1982; SRDB Ref ID: 14704 

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Bechtel, 1990, Health and Safety Plan for the Remedial Investigation/Feasibility Study-Environmental 

Impact Statement for Linde Air Products, 129-HSP-01 DRAFT; Bechtel National, Inc. (Bechtel); 

April 1990; SRDB Ref ID: 46311 

Bechtel, 1993, Remedial Investigation Report for the Tonawanda Site, DOE/OR/21949-300 Volume 

1; Bechtel National, Inc. (Bechtel); February 1993; SRDB Ref ID: 16304 and SRDB Ref ID: 9009 

Belmore, 1952, Dismantlement of Linde Air Products Co., correspondence; F. M. Belmore; December 

18, 1952; SRDB Ref ID: 14829 

DOE, 2008, FUSRAP Considered Sites Database Report, printout; Department of Energy (DOE); 

April 30, 2008; OSA Ref ID: 106081, pp. 6-9 

Hadlock, 1944, Experimentation on High-Grade Ores at the Linde Air Products Company, 

correspondence; Hadlock; February 26, 1944; OSA Ref ID: 105687, p. 43 

Harris, 1951, Reducing Exposures, single-page write-up; W. B. Harris; February 26, 1951; OSA Ref 

ID: 105687, p. 50 

Heatherton, 1948, Progress Report for the Seven Day Period Ending at 5:00 PM Friday, April 2; R. 

C. Heatherton; April 5, 1948; SRDB Ref ID: 14524 

Heatherton, 1949, Rehabilitation of Lake Ontario Ordnance Works; R, C. Heatherton; October 14, 

1949; OSA Ref ID: 105687, pp. 47-49 

Heatherton, 1950, Decontamination and Survey of Uranium Refinery Plant, NYO-1536; Richard C. 

Heatherton; December 14, 1950; SRDB Ref ID: 29822 

IT Corporation, 2000-2003, Radiation Dosimetry Reports from the Remediation of the Linde 

Ceramics Plant Site; IT Corporation and Landauer; 2000-2003; SRDB Ref ID: 50663 

IT Corporation, January 2002a, Final Status Survey-Survey Unit 010, Contract No. DACA31-95-D0083 TERC, Task Order No. 32; IT Corporation and US Army Corps of Engineers; January 2002; 

SRDB Ref ID: 49874 

IT Corporation, January 2002b, Final Status Survey-Survey Unit 011, Contract No. DACA31-95-D0083 TERC, Task Order No. 32; IT Corporation and US Army Corps of Engineers; January 2002; 

SRDB Ref ID: 49889 

IT Corporation, February 2002a, Final Status Survey-Survey Unit 009, Contract No. DACA31-95-D0083 TERC, Task Order No. 32; IT Corporation and US Army Corps of Engineers; February 2002; 

SRDB Ref ID: 49876 

IT Corporation, February 2002b, Final Status Survey-Survey Unit 007, Contract No. DACA31-95-D0083 TERC, Task Order No. 32; IT Corporation and US Army Corps of Engineers; February 2002; 

SRDB Ref ID: 49850 

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IT Corporation, February 2002c, Final Status Survey-Survey Unit 005, Contract No. DACA31-95-D0083 TERC, Task Order No. 32; IT Corporation and US Army Corps of Engineers; February 2002; 

SRDB Ref ID: 49879 

IT Corporation, February 2002d, Final Status Survey-Survey Unit 006, Contract No. DACA31-95-D0083 TERC, Task Order No. 32; IT Corporation and US Army Corps of Engineers; February 2002; 

SRDB Ref ID: 49883 

IT Corporation, February 2002e, Final Status Survey-Survey Unit 002; IT Corporation and US Army 

Corps of Engineers; February 2002; SRDB Ref ID: 49860 

IT Corporation, March 2002, Final Status Survey-Survey Unit 008, Contract No. DACA31-95-D-0083 

TERC, Task Order No. 32; IT Corporation and US Army Corps of Engineers; March 2002; SRDB 

Ref ID: 49887 

IT Corporation, September 2002, Final Status Survey-Survey Unit 015, Contract No. DACA41-01-D0031 KCPRAC, Delivery Order No.DN01; IT Corporation and US Army Corps of Engineers; 

September 2002; SRDB Ref ID: 49888 

Jones, 1985, Manhattan: The Army and the Atomic Bomb, select pages only; Vincent C. Jones; 1985; 

OSA Ref ID: 106081, pp. 13-15 

Kelley, 1949, Monthly Status and Process Report for March 1949, W. E. Kelley; April 7, 1949; OSA 

Ref ID: 105687, pp. 51-61 

Kent, 1948, Regarding Dust Hazards in the Ceramics Plant, correspondence; E. C. Kent; July 13, 

1948; OSA Ref ID: 105687, p. 66 

Kirk, 1954, Decontamination of Linde Air Products Company, Radiation Survey of April 14-15, 1954; 

R. L. Kirk; April 23, 1954; SRDB Ref ID: 11142, pp. 2-6 

Klevin, 1954, Decontamination of Buildings Used for Processing Alpha Emitters, select pages only; 

Paul B. Klevin, William B. Harris, and Hanson I. Blatz; April 29, 1954; SRDB Ref ID: 14830; OSA 

Ref ID: 105687 pp. 67-68 

Linde Drawing, 1937, Drawing A-63905, Layout Utility Tunnel, Linde Air Products Co., Engineering 

Dept., New York; 1936, amended February 9, 1937; SRDB Ref ID: Not yet in SRDB 

Linde Drawing, 1957, Drawing A-360164, Location Plan, 57” & 80” Utility Tunnels & Sewers for 

Northside of Property, Tonawanda, NY, Linde Air Products Co., Construction & Design Dept., 

Tonawanda, New York, March 20, 1957; SRDB Ref ID: Not yet in SRDB 

Linde Drawing, 1961, Drawing A-437867, Location Plan, Linde Company, Construction Engineering 

Dept., Tonawanda, New York; February 1, 1961; SRDB Ref ID: Not yet in SRDB 

Malone, 1956, Removal of Waste at Haist Property, memo to F. R. Dowling; F. W. Malone; May 29, 

1956; SRDB Ref ID: 6341 

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McKenzie, 2000, Results of the Independent Radiological Verification Survey of Remediation at 

Building 14, Former Linde Uranium Refinery, Tonawanda, New York (LI001V), ORNL/RASA-99/1; 

S. P. McKenzie and M. S. Uziel; July 2000; SRDB Ref ID: 8988 

Murray, 1992, Survey Report of the Radiological Characterization of the “Clean” Dirt Pile at the 

Linde Site, Tonawanda, New York, June 19, 1992, correspondence; Michael E. Murray; September 1, 

1992; SRDB Ref ID: 46334 pp. 5-6 

Name One, March 3, 2008, Linde Ceramics Special Exposure Cohort Application: January 1, 1954 

through July 31, 2006, Form B Non-standard; Name One; March 3, 2008; OSA Ref ID: 105432 

Name One, March 28, 2008a, Linde Ceramics SEC Petitions Addendum SEC Tracking Numbers: 

SEC00106 and SEC00107—Additional Issues and Supplementary Evidence Supporting Linde 

Ceramics Petitions SEC00106 and SEC00107; Name One; March 28, 2008; OSA Ref ID: 105723; 

OSA Ref ID: 105687, pp. 28-33 

Name One, March 28, 2008b, Linde Ceramics SEC Petition Application: November 1, 1947 through 

December 31, 1953, supporting document from the petitioner; Name One; March 28, 2008; OSA Ref 

ID: 105724; OSA Ref ID: 105687, pp. 3-27 

Name One, April 25, 2008, Additional Issues and Supplementary Evidence Supporting Linde 

Ceramics SEC Petitions SEC00106 November 1, 1947 through December 31, 1953 and SEC00107 

January 1, 1954 through July 31, 2006, supporting document from the petitioner; Name One; April 

25, 2008; OSA Ref ID: 105849 

Name One, May 20, 2008, Additional Issues and Supplementary Evidence Supporting Linde Ceramics 

SEC Petition SEC00107 January 1, 1954 through July 31, 2006, supporting document from the 

petitioner; Name One; May 20, 2008; OSA Ref ID: 106080 

Name Two, September 3, 2008, Personal Communication with Inventory Clerk/Rigger, Telephone 

Interview by ORAU Team HP and NIOSH HP; September 3, 2008; SRDB Ref ID: 48679 

Name Three, September 4, 2008, Personal Communication with Trades Helper/Pipefitter, Telephone 

Interview by ORAU Team HP; September 4, 2008; SRDB Ref ID: 48680 

Name Four, September 11, 2008, Personal Communication with Tool Maintenance/Inspector/Truck 

Lift Operator, Telephone Interview by ORAU Team HP; September 11, 2008; SRDB Ref ID: 48675 

Name Five, September 11, 2008, Personal Communication with Chemical Operator/Storesman, 

Telephone Interview by ORAU Team HP; September 11, 2008; SRDB Ref ID: 48676 

Name Six, September 11, 2008, Personal Communication with Chemical Operator, Telephone 

Interview by ORAU Team HP; September 11, 2008; SRDB Ref ID: 48677 

Name Seven, September 12, 2008, Personal Communication with Technologist, Telephone Interview 

by ORAU Team HP; September 12, 2008; SRDB Ref ID: 48678 

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Name Eight, April 10, 1981; Interview with [Name Eight Redacted], A Former Linde Employee, Oak 

Ridge Associated Universities Memorandum with attachments; April 10, 1981; SRDB Ref ID: 3745 

Name Nine, October 8, 2004, Email Communication with Name Nine, email with attachment; October 

8, 2004; SRDB Ref ID: 14580 

Name Ten, September 22, 2008, Personal Communication with [Name Ten Redacted], Telephone 

Interview by ORAU Team HP; September 22, 2008; SRDB Ref ID: 49406 

Name Eleven, March 4, 2010, Personal Communication with Electrician, Telephone Interview by 

ORAU Team HP; March 4, 2010; SRDB Ref ID: 80052 

Name Twelve, March 10, 2010, Personal Communication with Maintenance Staff Member, Telephone 

Interview by ORAU Team HP; March 10, 2010; SRDB Ref ID: 80055 

Name Thirteen, March 11, 2010, Personal Communication with Maintenance Staff Member, 

Telephone Interview by ORAU Team HP; March 11, 2010; SRDB Ref ID: 80056 

NIOSH, 2006, Report on Residual Radioactive and Beryllium Contamination at Atomic Weapons 

Employer Facilities and Beryllium Vendor Facilities, select pages only; National Institute for 

Occupational Safety and Health (NIOSH); December 2006; OSA Ref ID: 106081 pp. 10-12 

OCAS/DHHS, 2006, Correspondence Regarding the Addition of a Class of Employees to the Special 

Exposure Cohort, correspondence between OCAS and the Department of Health and Human Services 

(DHHS); OCAS and DHHS; January 12, 2006 and February 23, 2006; OSA Ref ID: 106081, pp. 2-5 

OCAS-PR-004, Internal Procedures for the Evaluation of Special Exposure Cohort Petitions, Rev. 0; 

National Institute for Occupational Safety and Health (NIOSH); Cincinnati, Ohio; September 23, 

2004; SRDB Ref ID: 32022 

OCAS-TIB-009, Estimation of Ingestion Intakes, Rev. 0; Office of Compensation Analysis and 

Support (OCAS); April 13, 2004; SRDB Ref ID: 22397 

ORAUT-OTIB-0070, Dose Reconstruction During Residual Radioactivity Periods at Atomic 

Weapons Employer Facilities, Rev. 00; Oak Ridge Associated Universities (ORAU); March 10, 2008; 

SRDB Ref ID: 41603 

ORAUT-TKBS-0025, An Exposure Matrix for Linde Ceramics Plant (Including Tonawanda 

Laboratory), Rev. 00 PC-1; Oak Ridge Associated Universities (ORAU); January 19, 2006; SRDB 

Ref ID: 22268 

ORNL, 1978, Formerly Utilized MED/AEC Sites Remedial Action Program—Radiological Survey of 

the Former Linde Uranium Refinery, Tonawanda, New York, W-7405-ENG-26; Oak Ridge National 

Laboratory (ORNL); May 1978; SRDB Ref ID: 14620 

Robinson, 1945, Sludge and P-V Cake to be Stored on the Haist Property, Memorandum for Captain 

R. E. Harris; Berwyn M. Robinson; July 16, 1945; SRDB Ref ID: 15426 

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Robinson, 1973, African Metals Corporation Residues; Robinson; March 6, 1973; SRDB Ref ID: 

14800 

SC&A, February 2008, Linde: Burlap Bag Issue Technical Call Notes, teleconference with SC&A, 

NIOSH, ORAU, Advisory Board, Linde Worker, and petitioner; notes created by S. Cohen and 

Associates (SC&A); February 13, 2008; OSA Ref ID: 105687, p. 40 

SC&A, June 2008, Linde: Radiation Exposure to Ore-Containing Burlap Bags—Revision 1, Working 

Draft; S. Cohen & Associates (SC&A); June 10, 2008; OSA Ref ID: 106340 

SC&A, December 2010, Clarification of SC&A Position on Radon in Utility Tunnels at Linde; S. 

Cohen & Associates (SC&A); December 6, 2010; SRDB Ref ID: Not yet in SRDB 

Shaw, January 2005a, Final Status Survey-Survey Unit 002: Building 14 Operable Unit Linde Site, 

Tonawanda, New York, Contract No. DACW41-01-D-0031 KCPRAC; Shaw Environmental, Inc. and 

US Army Corps of Engineers; January 2005; SRDB Ref ID: 49871 

Shaw, January 2005b, Utility Tunnel Exterior Characterization in Excavation Areas D2 and M South, 

Contract No. DACW41-01-D-0031, DN01, Letter to James D. Boyle, U.S. Army Corps of Engineers, 

Buffalo District, January 7, 2005; SRDB Ref ID: 82865 

Shaw, February 2005a, Final Status Survey-Survey Unit 004: Building 14 Operable Unit Linde Site, 

Tonawanda, New York, Contract No. DACW41-01-D-0031 KCPRAC; Shaw Environmental, Inc. and 

US Army Corps of Engineers; February 2005; SRDB Ref ID: 49865 

Shaw, February 2005b, Final Status Survey-Survey Unit 003: Building 14 Operable Unit Linde Site, 

Tonawanda, New York, Contract No. DACW41-01-D-0031 KCPRAC; Shaw Environmental, Inc. and 

US Army Corps of Engineers; February 2005; SRDB Ref ID: 49868 

Shaw, February 2005c, Final Status Survey-Survey Unit 005: Building 14 Operable Unit Linde Site, 

Tonawanda, New York, Contract No. DACW41-01-D-0031 KCPRAC; Shaw Environmental, Inc. and 

US Army Corps of Engineers; February 2005; SRDB Ref ID: 49873 

Shaw, March 2005, Final Status Survey-Survey Unit 001: Building 14 Operable Unit Linde Site, 

Tonawanda, New York, Contract No. DACW41-01-D-0031 KCPRAC; Shaw Environmental, Inc. and 

US Army Corps of Engineers; March 2005; SRDB Ref ID: 49863 

Thornton, 1976, Haist Property Fact Sheet; William T. Thornton; June 28, 1976; SRDB Ref ID: 

15431 

Unknown author, 1949, Handling Drums, correspondence; author not legible (unknown author); 

March 11, 1949; OSA Ref ID: 105687, pp. 45-46 

U.S. Army Corps, 1998, Demolition of Linde FUSRAP Site Building 30 Complete, News Release #98­

46; U.S. Army Corps of Engineers Buffalo District; September 21, 1998; SRDB Ref ID: 14577 

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U.S. Army Corps, 2002, Dose Assessment for the Existing Surface Contamination within the Linde
 

Utility Tunnel Complex, FUSRAP Remedial Action, Tonawanda, NY; U.S. Army Corps of Engineers,
 

Buffalo District; January 2002, SRDB Ref ID: 49892
 

Van Horn, 1944, Experimentation on High-Grade Ores at the Linde Air Products Company,
 

correspondence regarding previous letter on same subject; E. L. Van Horn; March 6, 1944; OSA Ref
 

ID: 105687, p. 44
 

Weinstein, 1954, Results of Decontamination Survey of the Step III Building Conducted During the
 

Period of February 9-11, 1954; Martin S. Weinstein; March 10, 1954; SRDB Ref ID: 11142, pp. 7-14
 

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Attachment 1: Data Sources on Uranium Progeny Concentrations in Linde 

Table A1-1: Data Sources on Uranium Progeny Concentrations in Linde Materials 

SRDB 

Ref ID Date Location Description U-238 U-234 U-235 Total U Th-230 Ra-226 Th­ 232 Th­ 228 Ac-227 Pa-231 Units Th

230

16294 1995 Bldg. 14 dry valve pit (dust) 1038 1068 53.8 2159.8 * 354.7 15.3 2.3 1.7 pCi/g 0.16 

sump (dust) 1.4 1.7 0.07 3.17 * 0.72 0.52 0.2 0.22 pCi/g 0.23 corridor overhead (dust) 369 378.8 11.6 759.4 * 60.2 0.14 ** 5 0.67 pCi/g 0.08 

corridor wall (terra cotta block) 3.2 3.2 0.14 6.54 * 1.7 1.4 1.4 1.4 pCi/g 0.26 

14620 1978 Bldg. 30 air samples during 

D&D 1.90E-08 2.10E­ 09 1.10E­ 09 pCi/ml 0.11 

9009 1981 Sediment, Ellicott Creek 0.82 0.05 1.69 * 0.6 0.55 0.7 pCi/g 0.36 

onsite & Creek 1 0.95 0.05 1.95 * 0.7 0.7 0.8 pCi/g 0.36 

offsite Twomile Creekupstream 4.3 0.1 8.7 * 0.92 0.69 0.01 pCi/g 0.11 

Twomile CreekLinde discharge 0.71 0.06 1.48 * 0.02 0.52 0.02 pCi/g 0.01 Twomile Creekdownstream 1.5 0.05 3.05 * 0.96 0.59 0.48 pCi/g 0.31 Storm Sewer 6.47 0.19 13.13 * 1.4 1.35 0.62 pCi/g 0.11 

Storm Sewer 99 4.57 202.57 * 18 6.93 0.51 pCi/g 0.09 Storm Sewer 13 0.52 26.52 * 2 1.59 0.65 pCi/g 0.08 Storm Sewer 116 4.1 236.1 * 9.9 0.89 0.34 pCi/g 0.04 Storm Sewer 4.5 0.17 9.17 * 0.2 0.64 0.39 pCi/g 0.02 Sanitary Sewer 362 13 737 * 1.33 1.94 0.11 pCi/g 0.00 Sanitary Sewer 0.51 ** 0.05 1.07 * 0.34 0.38 0.21 pCi/g 0.32 

9026 1990 Linde soil area 1-mean 11.2 22.4 * 7.8 4.3 1.6 pCi/g 0.35 

area 2-mean 12.7 25.4 * 5.7 3.4 1.4 pCi/g 0.22 

area 3-mean 17.1 34.2 * 24.4 9.4 1.4 pCi/g 0.71 area 4-mean 46.8 93.6 * 30.7 9.8 1.4 pCi/g 0.33 

8828 1981 Linde soil near disposal well­

& sediment subsurface (loc 24.05 0.84 48.94 * 5.9 5.53 0.92 14.25 0.73 pCi/g 0.12 

11) test well debris (loc 13) 26.4 1.09 53.89 * 3.53 0.82 0.51 2.1 0.29 ** pCi/g 0.07 sanitary sewer (loc 15) 362 12.93 736.93 * 1.33 1.14 0.11 5.54 0.95 pCi/g 0.00 storm sewer (loc 19) 99.2 4.57 202.97 * 17.7 6.93 0.51 14.29 1.14 pCi/g 0.09 storm sewer (loc 21) 116 4.1 236.1 * 3.89 0.89 0.34 3.07 0.39 ** pCi/g 0.02 

Notes: * calculated value ** <MDA, MDA shown 

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Attachment 2: Bounding Internal Dose from Particulates in the Linde Utili

Exposure to Radioactive Airborne Particulate Matter The Linde site is serviced by a series of underground tunnels that house gas, electrical, water, steam, telephone, and The maximum dimensions of the tunnel system were 8-10 ft high and 15 ft wide, with exhaust fans (approximately sdiameter) that pulled air through the tunnels (Name Eleven, March 4, 2010; Name Twelve, March 10, 2010; Name T11, 2010). These tunnels were routinely inspected and accessed for maintenance activities. However, no uranium-pever installed in these tunnels (U.S. Army Corps, 2002). The processing of uranium ore in the 1940s, resulted in contamination of the site building surfaces, soils, building susewer system. In addition, liquid waste effluent was injected into the subsurface injection wells. Runoff water contathese sources routinely flooded these service tunnels throughout the lifetime of the site resulting in a constant contamThese utility tunnels are routinely accessed by inspectors and maintenance personnel. A detailed radiological characterization performed in 2001 was based on beta surface contamination levels (U.S. ArmThe 95th percentile gross beta surface contamination level was determined based on an analysis of all of the gross be

Although the majority of this activity was likely fixed (as supported in the 1978 survey [ORNL, 1978]), 100% of the activity was assumed to be removable, and this was used to calculate an air concentration activity based on guidance Technical Information Bulletin, Dose Reconstruction During Residual Radioactivity Periods at Atomic Weapons Em(ORAUT-OTIB-0070). The resultant intakes are summarized in the Table A2-1 below. 

Table A2-1: Uranium and Uranium Progeny Exposure Summary for the Linde Utilities Tunnels 

Radionuclide Intake rates (dpm/year) Ingestion rates (dpm/year) 

Ra-226 116.071a,b 2.418a,b 

Th-230 132.124a,b 2.753a,b 

U-238 517.381a,b 10.779a,b U-235 24.696a,b 0.514a,b U-234 551.956a,b 11.499a,b 

a Values listed are assigned as a constant distribution. b Prorated for two months per year. 

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Attachment 3: Bounding Radon Dose in the Linde Utility Tunnel

A December 5, 2010 SC&A document, Clarification of SC&A Position on Radon in Utility Tunnels at Linde, includbounding radon in the Linde tunnels based on the known distribution of radon concentrations in basements in the are(SC&A, December 2010). In response, NIOSH performed a follow-up simulation using an expanded data set and soCounty, as opposed to the Niagara County numbers used in the original version of this evaluation report. NIOSH wifor the radon simulation as the Modified Source-term Model in the text below. The data set was expanded by using all the available measurements from the same set of boreholes used in the SC&A only the data from the top four feet of soil was used, even though some boreholes were carried down to eleven feet. the tunnels from all depths (not just the first four feet), it was considered reasonable to expand the data set to include measurements. It should also be noted that the original borehole samples were positively biased because they were tcontaminated locations identified during surface gamma surveys. The original SC&A evaluation inappropriately used the geometric mean and geometric standard deviation for radon Niagara County basements; the Linde site is actually located just south of the county line in Erie County. The Niagaradon in basements have a geometric mean of 1.09 pCi/L and a geometric standard deviation of 2.66 pCi/L; the correfigures are 1.68 pCi/L and 3.95 pCi/L. The source of these statistics is: Measured Basement Screening Radon Levels 2010, published the New York State Department of Health (http://www.health.ny.gov/environmental/radiological/raThe following text describes NIOSH’s simulation using the Modified Source-term Model and the expanded data set. concentration in Linde Ceramics tunnels (Rntunnels) was estimated using the following equation: 

Rntunnels = RnErie Co basements * RaLinde/RaErie Co 

Where: RnErie Co basements = Radon concentration reported for basements in Erie County 

RaLinde = Ra-226 concentration in soils at Linde Ceramics 

RaErie Co = Ra-226 concentration in soils in Erie County 

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The Erie County Ra-226 soil concentration is taken to be 0.636 pCi/g and is applied as a constant value. This numbenumber for Niagara County that SC&A calculated, using 1.81 ppm of uranium, and then proportionally increasing thCounty figure of 1.89 ppm. (Source: Lawrence Berkeley National Laboratory, http://eetd.lbl.gov/IEP/high-radon/daThe Ra-226 concentration in soils at Linde Ceramics was taken from 51 soil sample results from an aggregate 59 feeDiscrete probabilities were assigned for each foot of soil by assuming the concentration reported for each foot of soil probability of occurrence. Identical soil sample results were combined resulting in the 51 discrete concentrations anTable A3-1. 

Table A3-1: Ra-226 Concentrations in Soils at Linde Ceramics 

Ra-226 (pCi/g) Probability Ra-226 (pCi/g) Probability 

0.12 0.0169 0.86 0.0169 0.13 0.0169 0.88 0.0169 0.20 0.0169 1.00 0.0169 0.23 0.0169 1.03 0.0169 0.26 0.0169 1.06 0.0339 0.31 0.0169 1.19 0.0169 0.35 0.0169 1.20 0.0508 0.39 0.0339 1.35 0.0169 0.42 0.0169 1.50 0.0339 0.43 0.0169 1.54 0.0169 0.45 0.0339 1.66 0.0169 0.54 0.0169 2.12 0.0169 0.55 0.0169 2.20 0.0169 0.56 0.0169 2.40 0.0339 0.57 0.0169 2.50 0.0678 0.59 0.0169 2.60 0.0339 0.67 0.0169 3.20 0.0169 0.70 0.0169 3.44 0.0169 0.76 0.0169 14.1 0.0169 0.78 0.0339 39.1 0.0169 0.80 0.0339 213 0.0339 

0.82 0.0508 SUM =1.0000 

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The computer application @Risk was used to solve the equation for radon concentration in Linde Ceramics tunnels. applied according to the distribution described above. To solve the equation, ten simulations were run with 10,000 idiffering random seed numbers. Outputs of various percentile concentrations were averaged and are provided in Tab

Table A3-2: Calculated Radon Concentrations in Linde Tunnels 

Percentile pCi/L 

5 0.17 

10 0.32 15 0.48 20 0.66 25 0.87 30 1.12 35 1.41 40 1.76 45 2.19 50 2.70 55 3.34 60 4.16 65 5.26 70 6.73 75 8.84 80 12.26 85 18.20 90 32.52 95 99.31 

NIOSH proposes that the 95th percentile value of 99.31 pCi/L provides a plausible upper bound estimate for radon ex

utility tunnels for all years at the Linde site beginning from the first MED production through the present time. 

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